E/M sections of proposed fee schedule spark demand for unified policies

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Note:  The following article synopsis was NOT provided by HCPro. It was created by Find-A-Code/innoviHealth.

Article Overview

This article covers comments submitted on CMS’s proposed 2023 Medicare physician fee schedule, with focus on E/M-related proposals affecting prolonged services and split/shared visits. It summarizes the concerns raised by specialty societies, consultants, and other stakeholders about policy alignment, administrative burden, and consistency with CPT-based guidance. The piece is useful for physicians, coders, billing staff, and practice leaders tracking Medicare rulemaking and upcoming training implications.

Why This Topic Matters

CMS proposals affecting E/M documentation and payment policy can change workflow, compliance practices, and staff education planning. Understanding the direction of the final fee schedule helps organizations prepare for updates without training on provisions that may change before final release.

Article Sections

  1. Rulemaking

    Introduces the CMS proposed fee schedule context and stakeholder reaction to the agency’s planned E/M-related changes. Also references prior CMS rulemaking responses to public comments.

  2. Commenters pan prolonged services proposal

    Summarizes concerns from specialty groups and individual commenters regarding the proposed prolonged services policy and the need for alignment between CMS and CPT guidance.

  3. Split/shared rule receives scrutiny

    Reviews public feedback on CMS’s split/shared visit policy and the broader discussion around time-based and component-based approaches within Medicare physician fee schedule policy.

  4. Negotiations may continue

    Describes ongoing discussions among CMS, the AMA, and other stakeholders about potential alignment of E/M guidance and the timing of final rule publication.

What You Will Learn

  • The general areas of the proposed Medicare physician fee schedule drawing stakeholder comments
  • How commenters are responding to CMS’s E/M policy direction
  • Why prolonged services and split/shared visit policies are being discussed together
  • What kinds of organizations are engaging in the rulemaking process
  • Why practices are being advised to wait for the final rule before training staff

Who Should Read This

  • Physician practices
  • Medical coders
  • Billing staff
  • Compliance teams
  • Practice administrators
  • Coding educators

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